Quick answer: the transitional regime that lets crypto-asset service providers (CASPs) operate in Spain without MiCA authorisation ends on 1 July 2026. Providers registered with the Banco de España as of 30 December 2024 may keep offering their services until that date; after it, only providers authorised by the CNMV, or passported in from another European authority, may operate (MiCA, Regulation (EU) 2023/1114, Art. 143).
What ends on 1 July 2026
MiCA has applied in full to crypto-asset service providers since 30 December 2024. Spain chose the maximum 18-month transitional period, so firms already operating remain covered until 1 July 2026 without needing the new authorisation. From that date, providing crypto-asset services without the CNMV's CASP authorisation, or without a European passport, is no longer permitted. The CNMV has already published its authorisation criteria in a questions-and-answers document (December 2025).
Who it affects, and who it does not
The deadline affects CASPs: exchange platforms, crypto-asset custodians and services for the execution, advice on, or portfolio management of crypto-assets. These services fall within MiCA because they relate to crypto-assets that are not financial instruments.
It does not affect security tokens. A tokenised security (a share, a bond, a fund unit) is a financial instrument and sits outside MiCA (Regulation (EU) 2023/1114, Art. 2(4)): it falls under MiFID II (Directive 2014/65/EU) and, in Spain, under Ley 6/2023 (Spain's Securities Markets Law, LMVSI), and its on-chain registration runs through an ERIR (the entity responsible for the registration and recording of DLT-based securities). Confusing the two regimes is the costliest mistake in this field.
What to do if you are a CASP
- Confirm whether you were registered with the Banco de España as of 30 December 2024 and therefore covered by the transitional regime.
- Prepare and file the CASP authorisation application with the CNMV well before 1 July 2026; authorisation is not immediate.
- Review capital, governance, custody and conflict-of-interest requirements, along with the CNMV guidance (December 2025 questions and answers).
- If the model touches tokenised financial instruments, ring-fence that part clearly: it falls under MiFID II and the LMVSI, not under the CASP authorisation.
MiCA timeline
- 30 June 2024: the rules for e-money tokens (EMTs) and asset-referenced tokens (ARTs) apply, Titles III and IV.
- 30 December 2024: full application to the remaining crypto-assets and to CASPs, Titles II and V.
- 1 July 2026: the Spanish transitional regime for CASPs ends. From this date, only authorised providers operate.
What this means for you
If you provide crypto-asset services, the time to regularise your authorisation is running out: get the file moving. If your project is about issuing tokenised securities, the MiCA calendar is not your calendar; your framework is MiFID II, the LMVSI and the appointment of an ERIR.
Frequently asked questions
When exactly does the transitional regime end in Spain?
On 1 July 2026. Until then, providers registered with the Banco de España as of 30 December 2024 may keep operating.
Does the MiCA deadline affect security tokens?
No. Security tokens are financial instruments, excluded from MiCA (Art. 2(4)) and governed by MiFID II and the LMVSI.
What happens if I do not obtain the CASP authorisation in time?
From 1 July 2026 you will not be able to provide crypto-asset services in Spain without CNMV authorisation or a European passport.
This content is for general information and educational purposes only. It is not legal, tax or investment advice and does not replace consultation with a qualified professional. Regulation on tokenisation and crypto-assets evolves; always check the version in force of the rules cited in the BOE (boe.es) and EUR-Lex (eur-lex.europa.eu).